Melanie Kendall Reid, Director of Compliance, Carbon2018 commented:
“We are frequently faced with new legislative requirements that are constructed by government departments that do not understand the complexities of multi let properties and the landlord tenant relationship. Our Forum’s aim is to capture these at the consultation stage, offer a setting where any potential issues can be debated and provide comprehensive feedback to shape future requirements incorporating the needs of our clients.”

Chris Smith, Technical Manager at the National Measurement Office (NMO) also joined the forum to address questions specifically relating to the Heat Network Regulations (HNR) that came into force in December 2014.
Smith made it very clear that the NMO viewed its role in a support and guidance capacity rather than purely compliance.
The main concerns flagged were around feasibility studies that are not currently statutory so tenants can refuse to pay for them under the terms of their lease. The general feeling was if the feasibility studies were part of the statutory requirement this could be recharged to tenants.

Other key points raised and submitted to government include:
EPCs and DECs
There is a place in the market for both accreditations however the
assessments be incorporated which would paint a valuable picture of the
building fabric and performance. Substituting DECs for EPCs will only
enforce a requirement to measure the potential of the building’s energy
performance – not the behavior of its users.

Current energy legislation focuses on measuring usage and assessing the
capability of buildings rather than any statutory requirement to reduce
energy – this focus needs to change if the UK is to meet it’s 2050 climate
change target.

Electricity Market Reform and De-aggregation of gas
Tenants should expect to see their electricity and gas costs increase as a
result of these legislations due to the additional pass-through costs and gas
de-aggregation attracting a standing charge per supply during the second
quarter of 2015.

Renewable Heat Incentive
Building owners and occupiers could actually profit from this legislation. If
they can find the capital upfront to buy the equipment themselves then the
payback would be huge, as they would benefit from both using renewable
heat and the incentive itself.

The current consultation on this initiative is seeking feedback on whether
allowing third party finance and benefit would encourage wider uptake of
the scheme. Concerns were however raised over the longevity of the
arrangements in letting someone install equipment that they keep
ownership of due to potential issues with maintenance, access and any
future requirement to change how the space is used.

In a multi-tenanted building if would be particularly risky to hand over control of maintenance
and to enter into a long-term contract that the building would be tied into.
Plus what happens if you want to sell the building?

The final point made during the forum was legislation is only worthwhile if it delivers on what it intended and therefore it should be reviewed on a regular basis.

Smith from the NMO commented “the NMO report annually on the benefits they are delivering through the regulations they enforce so they can prove the financial return they bring for every £1 of taxpayers money.”

About Carbon2018
Carbon2018 was recently voted ‘Consultant of the Year’ by GVA West End Management. Our four decades of experience within energy management means we bring a wealth of knowledge to our clients helping them to make informed choices on their energy management strategies. We work in partnership to deliver real, quantifiable value through minimising costs, mitigating risks and reducing carbon emissions. To find out more, please view our website: www.carbon2018

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